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FCTD
3651541 Canada inc. v. Canada (Attorney General), 2007 FC 1255
* * * * * * * * * * [11] The Minister’s Delegate relies upon Information Circular 92-2 and the case of Young v. ... Canada (Customs and Revenue Agency) 2005 FCA 153, 2005 D.T.C. 5245 and Comeau c. Canada (Agence des douanes et du revenu), 2005 FCA 271, 361 N.R. 141). ...
FCTD
Tremblay v. Canada (Attorney General), 2013 FC 1049
[9] As for the standard of review, the Court is of the view that the standard of reasonableness applies to the decision of the minister’s delegate (Lanno v Canada (Customs and Revenue Agency), 2005 FCA 153, at paras 6-7, 139 ACWS (3d) 191 (Lanno); Telfer v Canada (Revenue Agency), 2009 FCA 23, at para 24, [2009] FCJ No 71 (QL) (Telfer); Dunsmuir v New Brunswick, 2008 SCC 9, [2008] 1 SCR 190 (Dunsmuir)). ... Several Federal Court decisions have confirmed this finding: Northview Apartments Ltd v Canada (Attorney General), 2009 FC 74, at para 11, 176 ACWS (3d) 882; Légaré v Canada (Customs and Revenue Agency), 2003 FC 1047, at para 10, [2004] 5 CTC 44; Babin v Canada (Customs and Revenue Agency), 2005 FC 972, at para 12, [2005] 4 CTC 1; Quastel v Canada (Revenue Agency), 2011 FC 143, at para 29, 2011 GTC 2016; Jones Estate v Canada (Attorney General), 2009 FC 646, at para 59-60, [2009] FCJ No 813 (QL); Fleet v Canada (Attorney General), 2010 FC 609, at para 29, [2010] 5 CTC 85. ... [18] For these reasons, the application for judicial review is dismissed. ...
FCTD
Humby Enterprises Limited v. RE, 2007 FC 1085
This written appraisal was received by the Sheriff’s Office on or about May 4, 2005. [18] On May 17, 2005, the Sheriff’s office received correspondence from Western Star Trails Newfoundland Limited, containing an estimate of goods seized from one of the Judgment Debtors. These goods were assessed at approximately $85,800.00. [19] In July 2005, the Applicant instructed the Sheriff to sell the seized property. ... However, on September 1, 2005, the CRA instructed the Sheriff to postpone the sale. ...
FCTD
Canada (National Revenue) v. 757746 Alberta Ltd., 2007 FC 834
Justice Blanchard BETWEEN: MINISTER OF NATIONAL REVENUE Applicant and 757746 ALBERTA LTD. and PAUL MOREL Respondents REASONS FOR ORDER AND ORDER [1] In these reasons I explain why I have found the Respondents to be in contempt of the Court’s Order of January 18, 2007. 1. ... On November 4, 2005, Ms. Engelhardtova met with Mr. Morel and requested books and records for the corporation as she was conducting a GST audit ordered by Canada Revenue Agency. ... Deputy Attorney General of Canada Edmonton, Alberta FOR THE APPLICANT No one appearing for the Respondents FOR THE RESPONDENTS ...
FCTD
Osmose-Pentox Inc. v. Société Laurentide inc., 2007 FC 504
As indicated previously, this ground is that certain paragraphs of my order on December 14, 2005, on their own or in conclusion with the statements made on May 5, 2003, and those made on May 13, 2003, were such that they meet the test. [37] I do not at all agree. [38] Here again, I do not intend to repeat or comment further on what my decision on December 14, 2005 established. ... Respondent PLACE OF HEARING: Montréal, Quebec DATE OF HEARING: April 30, 2007 REASONS FOR ORDER: PROTHONOTARY MORNEAU DATED: May 10, 2007 APPEARANCES: Jean-Luc Deveaux José Bonneau FOR THE APPLICANT Alain Chevrier Pierre Archambault FOR THE RESPONDENT SOLICITORS OF RECORD: Jean-Luc Deveaux Montréal, Quebec Dagenais & Ass. Montréal, Quebec FOR THE APPLICANT FOR THE APPLICANT Dunton Rainville LLP Montréal, Quebec FOR THE RESPONDENT ...
FCTD
Patterson v. Canada Revenue Agency, 2011 FC 1398
[6] The Applicant, pursuant to the Collective Agreement, had taken maternity leave from May 4, 2005 to May 3, 2006 and then Family Leave from May 2006 to October 2009. These absences meant that, in the five years leading up to the competitions (November 2005 to November 2010), she did not meet the 24-month experience requirement ... In Morris v Canada (Canadian Armed Forces), 2005 FCA 154 at para 27, 334 NR 316 [Morris], the Court of Appeal held that the legal definition of a prima facie case does not require that any particular type of evidence be adduced to prove the facts necessary to establish that the complainant was the victim of a discriminatory practice as defined in the Act. ...
FCTD
Abou-Rached v. Canada (Attorney General), 2019 FC 750
Specifically, as the respondent has pointed out, the applicant provided the CRA anywhere from 3 to 27 cheques in support of each year’s claim of $8500 income, as follows: (a) 2002:3 cheques totalling $8500 $1500 (May 15) + $4000 (Sept 12) + $3000 (Dec 20) (b) 2003:4 cheques totalling $8500 $2000 (Feb 18) + $3000 (May 3) + $3000 (Aug 6) + $1500 (Dec 2) (c) 2004:5 cheques totalling $8800 $2200 (Feb 2) + $800 (May 3) + $800 (June 1) + $2000 (June 4) + $3000 (Dec 21) (d) 2005:3 cheques totalling $8800 $3200 (April 1) + $1500 (July 25) + $3800 (Dec 20) Note: The cheques to cash from Garmeco for 2005 provided by RBC and reviewed by the auditor Wheatley total at least $28,300, from which the applicant had selected three cheques totalling $8500 to provide the CRA (CTR Tab 48, working paper entitled “Analysis of ‘cash’ payments by Garmeco Canada” for 2005). ... + $10 (March 30) + $121 (April 2) + $84 (April 20) + $57 (May 7) + $117 (May 23) + $132 (June 25) + $362 (June 29) + $86 (July 31) + $79 (Aug 31) + $83 (Oct 1) + 83 (Oct 30) + $63 (Nov 16) + $94 (Nov 16) + $79 (Nov 30) + $17 (Dec 18) + $160 (Dec 18) + $83 (Dec 31) Note: The applicant’s accountant also provided cheques to auditor Lin for 2007 that, as he did for 2006, showed additional amounts (Tab 16 of applicant’s record, letter from accountant to auditor Lin dated October 25, 2011, attached to the applicant’s affidavit, with copies of supporting cheques made out to cash for 2005, 2006 and 2007). [17] The applicant did not provide new documents during the second-level review conducted after the Court ordered the reconsideration of the matter. ... Indeed, the applicant obtained significantly more than $8500 in both 2005 and 2006 from cheques made out to cash (respectively $28,300 and $34,676, at CTR Tabs 48 and 52). ...
FCTD
Pylatuik v. Canada (Attorney General), 2016 FC 1394
The Applicant was initially assessed for the 2004, 2005 and 2006 taxation years by notices dated April 21, 2005, July 5, 2006, and July 19, 2007, respectively. ... The interest of $212,739.00 otherwise payable was thereby reduced to $25,848.00 in respect of the 2004, 2005 and 2006 tax years. ... iv. June 11, 2009- September 22, 2014 • As a result of the settlement of the appeal to the Tax Court of Canada and the second reassessment, the first reassessment in respect of the 2004 and 2005 taxation years was fully reversed and the reassessment for the 2006 taxation year partially reversed. ...
FCTD
Solomenescu v. Canada (Attorney General), 2009 FC 544
[11] I do not agree with the applicant’s submission. In fact, the amount indicated in the Agency’s statement of income tax arrears of January 9, 2006 ($2,984.73) is within pennies precisely the prorated difference over the 180 days between the amounts noted on the statement of account for September 9, 2005 ($2,915.71) and March 7, 2006 ($3,317.54) ... ATTORNEY GENERAL OF CANADA PLACE OF HEARING: Ottawa, Ontario DATE OF HEARING: March 17, 2009 REASONS FOR JUDGMENT: LUTFY C.J. ... Deputy Attorney General of Canada Ottawa, Ontario FOR THE RESPONDENT ...
FCTD
Canada (National Revenue) v. CD²I Coopérative de Services en Développement International, 2009 FC 820
Le nom de tous les membres faisant partie des personnes ayant investi un montant nominal (membres autres que ceux qui ont transféré un REER ou tout autre placement enregistré à CD²I) à un moment ou à un autre et faisant partie des membres de la coopérative pour les années 2003, 2004 et 2005. Nous aimerions obtenir à leur égard leur adresse ainsi que leur pourcentage de participation pour chacune des années 2003, 2004 et 2005. b. Tous les relevés bancaires de tous les comptes bancaires de la coopérative CD²I pour l’année 2005 ainsi que les livres comptables et pièces justificatives expliquant les dépôts et les retraits ...